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The Upper Tribunal (UT) has ruled that a taxpayer could not claim relief from Capital Gains Tax (CGT) on a loan to a company that had been discharged in exchange for new shares, because the loan was no longer 'outstanding' when the claim for relief was made....
In a case which illustrates the likely approach courts and tribunals will take to anti-avoidance legislation, the First-tier Tribunal (FTT) has found that a holding company's non-trading loan relationship deficits could not be set off against its profits ...
It is a general rule that payments in the nature of penalties may not be deducted for the purpose of calculating taxable profits. The Court of Appeal recently considered whether the rule prevented payments made to consumers and consumer organisations in...
The First-tier Tribunal (FTT) has found that work undertaken by a company to convert a warehouse into a car showroom qualified for Business Premises Renovation Allowance (BPRA), a 100 per cent tax allowance available between 2007 and 2017 on qualifying...
As announced in the Autumn Budget 2024, the van benefit charge and the car and van fuel benefit charges are to increase from 6 April 2025, in line with the Consumer Price Index. The van benefit charge applies where an employer provides an employee with a...
A company has succeeded in reducing VAT default surcharges of more than £9,000 after the First-tier Tribunal (FTT) found that HM Revenue and Customs (HMRC) had not demonstrated that a notice in respect of an earlier default surcharge had been...
A telecoms provider has lost its appeal against a decision that, where customers were offered discounts for early payment, VAT was payable on the full amount charged if the discount was not accepted. Between 1 January and 30 April 2014, the telecoms...
In a case concerning the employment status of part-time football referees , the Supreme Court recently concluded that the relationship between them and the company that provided their services demonstrated both sufficient mutuality of obligation and...
Where a partnership's members include one or more companies, the profits of the partnership are calculated as if its trade was carried on by a company, by virtue of Section 1259 of the Corporation Tax Act 2009 . Recently, the Upper Tribunal (UT) ruled on...
Disagreements with HM Revenue and Customs (HMRC) can be complicated and protracted, but it is vital to comply with deadlines at every stage of the process. In a recent case, a limited liability partnership (LLP) failed to convince the Upper Tribunal (UT)...
